Decoding Organic Certification for Flavors

August 25, 2023

Ever wonder what organic certification means for the flavor industry? We dive into this with an interview with our certification body.

In this interview, we undercover what it truly means to be organic certified in the flavor arena. We interviewed Mario Velazquez, an expert on certification from QAI.

  1. What is the primary difference between organic certification and organic compliant statements when it comes to flavors in the food and beverage industry?

    Organic certification of a flavor is achieved when a certification body confirms that all the flavor’s components were reviewed and found compliant with federal regulations.
    Some suppliers provide what they call “organic compliant statements,” arguing that the ingredients on the flavor comply with the regulations. While this may be true, these ingredients cannot be marketed, sold, or treated as “Organic.”

    Organic compliant statements are not the same as organic certifications, and even with these statements, all ingredients are subject to full review against regulations. Operations must submit required documentation to their certification body when adding a non-organic flavor, and an organic-compliant statement does not supersede this requirement.
  2. What are the specific criteria and standards that need to be met to obtain organic certification for flavors?

    When certifying flavors to an “Organic” claim, all agricultural ingredients must be organically certified or listed on 7 CFR 205.606. Operations must demonstrate that non-organic agricultural ingredients are not available in organic form.

    Flavors requesting a “Made with Organic” claim must be composed of organic ingredients, and additional non-organic agricultural ingredients may be used regardless of whether listed on 7 CFR 205.606 or not.

    For both claims, “Organic” and “Made with Organic,” documentation must be presented, proving that all non-organic ingredients have been produced without excluded methods, nanotechnology, nor GMOs.

    Finally, all non-agricultural ingredients must appear on the National List in 7 CFR 205.605.
  3. How do organic compliant statements differ from organic certification in terms of credibility and consumer trust?

    Organic certification entails a process of several review steps and approval. Certification can only be granted through accredited certification bodies such as Quality Assurance International (QAI). For a facility and its products to receive organic certification, it must undergo an initial review stage, during which technical reviewers verified the facility’s SOPs, flow charts, equipment and lines, organic training materials, supplier lists, formulas, ingredient composition, and labels, amongst other criteria. Once the application is deemed complete & compliant, an initial audit verifies the review onsite. This grants credibility in the process through thorough and exhaustive reviews and supports consumer trust as this process is repeated annually during the client’s renewal audit.

    Compliant statements often simply cite regulations. These are self-issued by manufacturers or suppliers, are not verified by certification, and do not involve a full document review.
  4. Are there any legal or regulatory differences between organic certification and organic compliant statements for flavors? If so, what are they?

    After an initial audit, organic certification is granted by a third-party certification body that has been authorized by the standard owner (such as USDA for the National Organic Program, Canada Organic Regime, EU Organic, Ley de Productos Organics, etc.). These accredited certification bodies have processes and procedures, as well as technical review staff, which ensure the ingredients and processes through which these flavors are produced comply with the applicable federal standards and regulations. Furthermore, these organizations are accredited and audited yearly to ensure they are also compliant with the regulations: 7 CFR Part 205 Subpart F.

    Organic compliant statements are not the same as certification and are not federally regulated. Most certification bodies will require additional information on the non-organic flavors and cannot accept a compliant statement by itself.
  5. What are the potential benefits of obtaining organic certification, and how can it positively impact a food or beverage product's marketability?

    The USDA National Organic Program (NOP) standards require the use of organic flavors in all products seeking Organic certification. The NOP only allows non-synthetic flavors when the organic version is not commercially available. Such flavors are only be approved alongside an “Organic Flavor Commercial Availability Plan.” The purpose of this plan is to help keep track as the manufacturer seeks an organic-certified version. Therefore, non-synthetic flavors are only temporarily approved.

    The demand for organic flavors will only increase in the market, and the use of their non-organic counterparts do not always meet the requirements for organic flavors, thus often deeming them non-compliant.
  6. In the absence of organic certification, what information or documentation is required for a flavor to be considered organic compliant?

    Requirements for certification vary depending on the standard (NOP, Canada Organic Regime (COR), EU Organic, Ley de Productos Organics (LPO), etc.). The flavor must meet the definition of natural flavor for FDA (for NOP-certified clients), CFIA (for COR clients), Council Directive 88/388/EEC (14) (for EU-certified clients), or Codex Alimentarius (for LPO-certified clients).

    For NOP, natural flavors must not be produced using synthetic extraction solvents and must not contain any synthetic carrier systems or any artificial preservatives. There are other requirements for the ingredients. For example, if glycerin is used as a carrier or solvent within flavors under NOP or COR, it must be produced according to glycerin annotations under 205.606, or Table 6.3 of the Permitted Substances List for NOP and COR operations, respectively. The natural flavor must be produced and handled without the use of excluded methods, nanotechnology, nor GMOs.

    Certification bodies require the submission of documentation confirming compliance with all requirements prior to approval.
  7. How does the certification process for flavors differ from the certification process for other organic products, such as fruits or vegetables?

    Flavors are complex products and, in most cases, contain multiple ingredients. The certification process usually includes the review of organic and non-organic sub-ingredients. Sometimes, it also involves the review of manufacturing processes, flow charts, and equipment, which may involve technical reviewers. As such, the certification of organic flavors takes more time and requires more technical expertise.
  8. Are there any ongoing monitoring or auditing processes involved in maintaining organic certification for flavors, and how frequently are these evaluations conducted?

    Organic flavors are reviewed and approved at any moment during the certification year and are also verified during the annual renewal audit. Should any certified formula ever change its recipe, the flavor must be reviewed and approved once more prior to being sold.
  9. Are there any specific labeling requirements or restrictions for products with organic flavors, and how do these differ between certified and compliant products?

    Flavors certified as “Organic” or “Made with Organic” must comply with the requirements established on the 7 CFR Part 205 Subpart D.

    Non-organic flavors must meet the FDA/CFIA/EEC/LPO requirements both for processing and labeling.

About the author:

Mario Velazquez was born in Santurce, Puerto Rico in 1988. He has a bachelor’s degree in literature from the University of Puerto Rico – Rio Piedras. During the summer of 2013, he moved to Mexico where he worked in a fresh cut fruit processing plant—he worked in all departments from Receiving to Production, finally holding the position of Document Controller & Internal Auditor. He worked as part of a team helping farms and processing operations comply with multiple standards and certifications in Mexico and Guatemala.

In 2018, he started working with Quality Assurance International. Since then, he has worked as an Organic Auditor for a year and a half, and is currently an Account Manager, supporting multiple key accounts on their certification processes. His hobbies include backpacking, mountain unicycling & running.